Case Summary (G.R. No. 14639)
Factual Background
In October 1918, Mayor Lukban ordered the closure of Manila’s segregated “vice district.” Between October 16 and 25, police confined roughly 170 women to their district homes, then forcibly placed them aboard steamers bound for Davao. The women were neither informed of the true purpose nor given opportunity to collect belongings or grant consent. In Davao they were received as laborers by Governor Sales and Ynigo. Many later dispersed, some returned to Manila at personal expense, others remained or married locally.
Procedural History
On October 25, relatives’ counsel filed a habeas corpus petition before the Supreme Court of the Philippines claiming illegal restraint by Manila officials. The writ was made returnable before the full Supreme Court. Respondents admitted detention and deportation but raised objections as to parties, venue (urging Davao CFI), absence of custody, and territorial limits of Manila authorities.
Legal Issues Presented
- Whether the Supreme Court could issue a habeas corpus writ enforceable across provincial boundaries.
- Whether respondents’ acts amounted to unlawful restraint under applicable law.
- Whether any statutory or regulatory authority justified deportation of Philippine citizens from Manila to Davao.
- Whether respondents complied with court orders and, if not, whether contempt sanctions should issue.
Applicable Law in 1919
– Organic Act of 1902: Guarantees personal liberty and due process under U.S. administration.
– Act No. 519 and Manila R.O. § 733: Criminalize prostitution and confer penal jurisdiction, but do not authorize forced deportation.
– Act No. 899: Concerns return of U.S. citizens convicted of vagrancy.
– Penal provisions (Art. 211, Penal Code): Prohibit public officers from banishing persons or compelling domicile change without lawful authority.
– Code of Civil and Criminal Procedure: Sections on habeas corpus jurisdiction, party standing, returns, and contempt.
Court’s Jurisdiction and Venue Analysis
The Supreme Court held it had authority under procedural statutes to grant and enforce habeas corpus writs anywhere in the Islands. Although petitions normally go to the nearest CFI, exigent circumstances—petitioners and respondents counsel in Manila, risk of continued restraint, women scattered—justified returnable hearing before the Supreme Court.
Restraint of Liberty Determination
“The forcible taking” and transport of petitioners amounted to involuntary restraint of liberty equal to imprisonment. Detention continued until voluntary return or lawful court order. Territorial removal did not end the restraint, nor did the shift of custody absolve Manila officials of responsibility to restore liberty.
Habeas Corpus as Exclusive Fast Remedy
Civil actions and criminal prosecution for illegal deportation were available but too slow. Habeas corpus is a “speedy and effectual” safeguard of personal freedom. The absence of any law authorizing municipal officials to deport citizens rendered the detention unlawful, warranting issuance of the writ.
Respondents’ Defenses Rejected
– Standing: Relatives could file on behalf of detained women unable to petition themselves.
– Venue: Supreme Court discretion allowed central hearing.
– Custody: Officials who initiated unlawful transfer remain responsible until liberty restored.
– Consent: Presence of police at night and stealthy methods disprove voluntary departure.
No statute authorized forcible domicile change by the Mayor or Chief of Police; Penal Code imposed clear penalties for such conduct.
Contempt Proceedings and Compliance
First Order (Nov. 4): Directed respondents to produce detainees Dec. 2. No significant effort until Nov. 21 telegram; seven women returned independently. Return offered only a
Case Syllabus (G.R. No. 14639)
Facts of the Case
- During October 16–25, 1918, Manila’s segregated district for “women of ill repute” was forcibly closed by order of Mayor Justo Lukban.
- Approximately 170 women were confined in their homes, then at midnight on October 25 hustled into patrol wagons and placed aboard the steamers Corregidor and Negros.
- The women were neither informed of their true destination nor asked to consent; they believed they were taken for police investigation.
- They arrived in Davao on October 29, 1918, and were received as laborers by Governor Francisco Sales, Feliciano Ynigo, and Rafael Castillo—who had no prior notice of their status as deportees.
- Subsequent fates varied: some married, others worked, some disappeared, and a significant number returned to Manila on their own.
Petition and Writ of Habeas Corpus
- Relatives and friends of the deported women filed an application for habeas corpus before a member of the Supreme Court, later made returnable before the full Court.
- Petitioners alleged illegal restraint of liberty by Mayor Lukban, Chief of Police Anton Hohmann, and unnamed parties.
- On November 4, 1918, the Supreme Court granted the writ, directing Lukban, Hohmann, Sales, and Ynigo to produce the women before it on December 2, 1918.
Respondents’ Answer and Defenses
- The city fiscal, appearing for Lukban and Hohmann, admitted sequestration and deportation but argued:
• Petitioners lacked proper standing;
• The proper venue was the Court of First Instance in Davao;
• Respondents had no custody or control of the women at the time of return;
• Their jurisdiction did not extend beyond Manila’s limits. - Exhibits stated the women were destined as laborers at good salaries on Davao haciendas.
- Affidavits were offered portraying the women as content in Mindanao and unwilling to return.
Proceedings and Supreme Court Orders
- On December 2, 1918, no respondents produced the women; seven had already returned independently.
- Respondents repeated earlier defenses, offered telegrams and affidavits, and Sales and Ynigo claimed lack of control.
- On December 10, 1918, the Court issued a second order: produce remaining women by January 13, 1919, unless they renounced the writ in writing or compliance proved legally impossible.
- Additional testimony was take